Case 6:20-cv-00212-ADA Document 1-2 Filed 03/23/20 Page 1 of 13
`
`Exhibit 2
`
`

`

`Case 6:20-cv-00212-ADA Document 1-2 Filed 03/23/20 Page 2 of 13
`
`Exemplary Accused Product
`
`U.S. Patent No. 9,823,784 (“’784 Patent”)
`
`The Apple iPhone 11 Pro Max (“Apple iPhone 11 Pro Max”) infringes at least Claim 1 of the ’784 Patent.
`
`Claim 1
`
`[1pre] A sensor comprising:
`
`Apple iPhone 11 Pro Max
`
`The Apple iPhone 11 Pro Max includes a sensor. For example, the Apple iPhone 11 Pro Max
`includes a touch sensor, a touch controller, and an Apple A13 system on a chip platform that
`controls, among other things, the device’s touch sensing capability.
`
`For example, the Apple A13 system on a chip platform works in conjunction with the Apple iPhone
`11 Pro Max’s touch controller to control the device’s touch sensor, including performing
`measurements on signals from the touchscreen:
`
`The Apple iPhone 11 Pro Max’s touch controller is connected to and controls a touchscreen (touch
`sensor):
`
`
`
`Page 1
`
`

`

`Case 6:20-cv-00212-ADA Document 1-2 Filed 03/23/20 Page 3 of 13
`
`Claim 1
`
`Apple iPhone 11 Pro Max
`
`https://www.apple.com/iphone/compare/ (annotated).
`
`[1a] a substrate; and
`
`The Apple iPhone 11 Pro Max includes a substrate.
`
`For example, the Apple iPhone 11 Pro Max includes a substrate placed between the drive and sense
`electrodes. The drive and sense electrodes are each formed of a transparent conductor such as
`indium tin oxide. Based on microscopic inspection of the Apple iPhone 11 Pro Max’s touch sensor,
`two distinct layers are observed, indicated by different patterns of breaks in the ITO pattern. The
`two layers are separated by a nonconductive substrate in order to isolate the drive electrodes from
`the sense electrodes The physical details of the two layers of electrodes are shown and described in
`connection with limitation [1c] below.
`
`[1b] a sensing region
`configured to sense a
`position of an object within
`the sensing region,
`
`The Apple iPhone 11 Pro Max includes a sensing region configured to sense a position of an object
`within the sensing region.
`
`For example, the Apple iPhone 11 Pro Max includes a touchscreen configured to sense the position
`of a finger within the sensing region.
`
`See limitation [1a].
`
`See also, e.g.:
`
`Page 2
`
`

`

`Case 6:20-cv-00212-ADA Document 1-2 Filed 03/23/20 Page 4 of 13
`
`Claim 1
`
`Apple iPhone 11 Pro Max
`
`https://developer.apple.com/documentation/uikit/touches_presses_and_gestures/handling_uikit_gest
`ures
`
`
`
`Page 3
`
`

`

`Case 6:20-cv-00212-ADA Document 1-2 Filed 03/23/20 Page 5 of 13
`
`Claim 1
`
`Apple iPhone 11 Pro Max
`
`
`
`Page 4
`
`

`

`Case 6:20-cv-00212-ADA Document 1-2 Filed 03/23/20 Page 6 of 13
`
`Claim 1
`
`Apple iPhone 11 Pro Max
`
`[1c] the sensing region
`comprising: a plurality of
`drive electrodes disposed on
`a first side of the substrate in
`a first layer: and a plurality
`of sense electrodes disposed
`on a second side of the
`substrate in a second layer so
`that the sense electrodes
`intersect the drive electrodes
`at a plurality of intersections
`offset by a thickness of the
`substrate,
`
`https://developer.apple.com/documentation/uikit/touches_presses_and_gestures/handling_touches_i
`n_your_view
`
`In the Apple iPhone 11 Pro Max, a plurality of drive electrodes disposed on a first side of the
`substrate in a first layer: and a plurality of sense electrodes disposed on a second side of the
`substrate in a second layer so that the sense electrodes intersect the drive electrodes at a plurality of
`intersections offset by a thickness of the substrate.
`
`For example, the Apple iPhone 11 Pro Max includes a touchscreen, wherein the sensing area of the
`touchscreen includes drive electrodes disposed on a first layer and sense electrodes disposed on a
`second layer such that the drive and sense electrodes intersect at a plurality of intersections and are
`separated by the thickness of the substrate.
`
`In the annotated images below, the plurality of drive electrodes disposed on the first side of the
`substrate are depicted in blue, and the plurality of sense electrodes disposed on the second side of
`the substrate are depicted in red. The drive electrodes run along the long axis of the device, and the
`sense electrodes run perpendicular to those. There are fewer drive electrodes than sense electrodes.
`A simple test confirms that the longer blue electrodes are the drive electrodes: an oscilloscope probe
`was moved over the face of the device, showing that there was substantially no change in the
`capacitive drive signal as the probe was moved along the long axis of the device (substantially the
`same capacitive drive signal was present along the entire length of the drive electrode) but there was
`a substantial change in the capacitive drive signal as the probe was moved along the short axis of the
`device (different drive signals present on different drive electrodes).
`
`Page 5
`
`

`

`Case 6:20-cv-00212-ADA Document 1-2 Filed 03/23/20 Page 7 of 13
`
`Claim 1
`
`Apple iPhone 11 Pro Max
`
`Annotated microscope image showing first layer of drive electrodes in Apple iPhone 11 Pro Max,
`showing several of the plurality of drive electrodes in blue. Breaks in this ITO layer are marked in
`yellow.
`
`
`
`Page 6
`
`

`

`Case 6:20-cv-00212-ADA Document 1-2 Filed 03/23/20 Page 8 of 13
`
`Claim 1
`
`Apple iPhone 11 Pro Max
`
`Annotated microscope image showing second layer of sense electrodes in Apple iPhone 11 Pro
`Max, showing several of the plurality of sense electrodes in red. Breaks in this ITO layer are marked
`in green.
`
`
`
`Due to the perpendicular patterning of the sense and drive electrodes, the sense electrodes intersect
`the drive electrodes at a plurality of intersections offset by a thickness of the substrate.
`
`Page 7
`
`

`

`Case 6:20-cv-00212-ADA Document 1-2 Filed 03/23/20 Page 9 of 13
`
`Claim 1
`
`[1d] wherein the plurality of
`drive electrodes are
`substantially area filling
`within the sensing region
`relative to the plurality of
`sense electrodes;
`
`Apple iPhone 11 Pro Max
`
`In the Apple iPhone 11 Pro Max, the plurality of drive electrodes are substantially area filling within
`the sensing region relative to the plurality of sense electrodes.
`
`For example, the Apple iPhone 11 Pro Max includes a plurality of drive electrodes that substantially
`cover the sensing region relative to the sense electrodes in the same sensing region.
`
`Page 8
`
`

`

`Case 6:20-cv-00212-ADA Document 1-2 Filed 03/23/20 Page 10 of 13
`
`Claim 1
`
`Apple iPhone 11 Pro Max
`
`Annotated microscope image showing first layer of drive electrodes in Apple iPhone 11 Pro Max,
`showing several of the plurality of drive electrodes (in blue) substantially filling the sensing region.
`
`
`
`Page 9
`
`

`

`Case 6:20-cv-00212-ADA Document 1-2 Filed 03/23/20 Page 11 of 13
`
`Claim 1
`
`[1e] wherein a gap between
`adjacent sense electrodes has
`a width that is at least three-
`fifths of the pitch of the
`sense electrodes;
`
`Apple iPhone 11 Pro Max
`
`In the Apple iPhone 11 Pro Max, a gap between adjacent sense electrodes has a width that is at least
`three-fifths of the pitch of the sense electrodes.
`
`For example, the Apple iPhone 11 Pro Max includes sense electrodes having a gap width that is at
`least three-fifths of the pitch of the sense electrodes.
`
`Adjacent sense
`electrodes
`
`The gaps between adjacent sense electrodes are
`at least three-fifths of the pitch.
`
`Pitch of the
`sense
`electrodes
`
`
`
`
`
`Photograph of an Apple iPhone 11 Pro Max (annotated).
`
`
`
`Page 10
`
`

`

`Case 6:20-cv-00212-ADA Document 1-2 Filed 03/23/20 Page 12 of 13
`
`Apple iPhone 11 Pro Max
`
`In the Apple iPhone 11 Pro Max, the sensing region further comprises a plurality of isolated
`conductive elements disposed on the second side of the substrate between the sense electrodes so
`that, together, the plurality of sense electrodes and the plurality of isolated conductive elements are
`substantially area filling within the sensing region relative to the plurality of sense electrodes.
`
`For example, the Apple iPhone 11 Pro Max includes a plurality of conductive elements disposed on
`a second layer between the sense electrodes to fill the sensing area relative to the sense electrodes
`disposed on the second layer.
`
`Claim 1
`
`[1f] wherein the sensing
`region further comprises a
`plurality of isolated
`conductive elements
`disposed on the second side
`of the substrate between the
`sense electrodes so that,
`together, the plurality of
`sense electrodes and the
`plurality of isolated
`conductive elements are
`substantially area filling
`within the sensing region
`relative to the plurality of
`sense electrodes.
`
`Page 11
`
`

`

`Case 6:20-cv-00212-ADA Document 1-2 Filed 03/23/20 Page 13 of 13
`
`Claim 1
`
`Apple iPhone 11 Pro Max
`
`Isolated conductive
`elements (outlined
`in green) on second
`side of substrate
`between sense
`electrodes.
`
`Sensing region
`
`Sense
`electrodes
`(red)
`
`Photograph of an Apple iPhone 11 Pro Max (annotated).
`
`
`
`
`
`Page 12
`
`